Whistleblower Policy /

1. Purpose

The National Rugby League (NRL) is committed to the highest standards of behaviour and ethical conduct in all our business activities and promotes a culture of honest and ethical behaviour, corporate compliance and good corporate governance.

This Whistleblower Policy (Policy) sets out a process for persons to raise concerns regarding suspected unethical, illegal, fraudulent or other misconduct involving the NRL or the Australian Rugby League Commission (ARLC) and provides certain protections so that individuals who make a report may do so safely, securely and with confidence that they will be protected and supported.

This Policy is consistent with, and reinforces, the NRL’s beliefs of inclusivity, positivity, unity and discipline.

2. Who does this policy apply to? Eligible whistleblowers

This Policy applies to all directors, officers and employees of the NRL and ARLC.

Volunteers, contractors or other people associated with the NRL may also make a report under this Policy if they have reasonable grounds to suspect that Reportable Conduct (as defined in section 3 below) has occurred.

3. What matters should be reported under this policy?

A. Reportable Conduct

You may make a report under this Policy if you have reasonable grounds to suspect that a director, officer, employee, contractor, supplier or other person who has business dealings with the NRL or ARLC has engaged in misconduct or an improper state of affairs, including:

• dishonesty, fraud or corruption;
• illegal activities;
• breach of any State or Federal law, including tax laws;
• unethical financial practices, financial irregularities or misrepresentation of financial or other business information;
• conduct in breach of the NRL’s policies (noting that a breach of policy is handled in accordance with the relevant NRL policy and grievance process);
• unsafe work practices or practices which may harm the health or safety of NRL’s staff, contractors or members of the public;
• harassment, discrimination, victimisation (other than personal work-related grievances which should be reported in accordance with the NRL Grievance Policy); or
• attempts to conceal any misconduct or improper state of affairs.

All such conduct is described in this Policy as Reportable Conduct.

Reportable Conduct also includes any conduct which comprises retaliation against a person who raises concerns under this policy or who helps address a concern.

B. What sorts of disclosures are not reportable under this Policy?

You must have reasonable grounds for reporting a matter under this Policy. A mere allegation without any supporting information is unlikely to amount to Reportable Conduct. In most instances, you will need to provide information to assist in the investigation of the wrongdoing disclosed.

Personal, work-related grievances should be reported in accordance with the relevant NRL employee policy. These policies can be accessed via the NRL staff intranet or by contacting a member of the NRL People and Culture team. The disclosure of a personal, work related grievance is not protected by this Policy or the whistleblower protections in the Corporations Act 2001 (Cth). Examples of a personal work-related grievance include:

• an interpersonal conflict between the discloser and another employee;
• a decision that does not involve a breach of workplace laws;
• a decision about the engagement, transfer or promotion of the discloser;
• a decision about the terms and conditions of engagement of the discloser; or
• a decision to suspend or terminate the engagement of the discloser, or otherwise to discipline the discloser.

A suspected breach of the NRL Rules should be reported to the NRL Integrity and Compliance Unit in accordance with those rules. The NRL Integrity and Compliance Unit has established a dedicated hotline for whistleblowers who wish to make a disclosure in relation to a breach or suspected breach of the NRL Rules. Information regarding this service is available at

4. How do I make a report?

The NRL has several channels for making a report if you become aware of an issue which you consider to be Reportable Conduct:

NRL employees and contractors should raise reports of Reportable Conduct with the senior manager or executive responsible for your business unit.

Alternatively, you may raise a report with any of the Protected Disclosure Officers listed below:

Additionally, you may make a report to the NRL Whistleblower Hotline, which is a free external service run by Stopline. Stopline has several methods whereby a disclosure about reportable information can be received:

Telephone (in Australia): Toll Free - 1300 30 45 50

Online:

Email: nrl@stopline.com.au

Mobile Telephone App: Free download from Apple iTunes store and Google Play

Locked Bag Mail:

The STOPline
Locked Bag 8
Hawthorn VIC 3122
Ref: National Rugby League – Protected Disclosure Officer

Disclosures to Stopline can be made during business hours (08:00am - 08:00pm, Monday to Friday AEST). Any messages left will be responded to within one (1) business day.

The Stopline operator will provide details of your report to a Protected Disclosure Officer so that the matter can be investigated by the NRL. However, they will only provide your contact details to the Protected Disclosure Officer with your consent.

A report may be made anonymously using any of the methods outlined above.

You will also obtain protection under this Policy if you disclose Reportable Conduct to a director, officer or other senior manager of the NRL or ARLC, or to certain persons outside the organisation, including to your legal practitioner, auditor, or a regulatory authority or other person identified in the Corporations Act 2001 (Cth).

The NRL is committed to protecting eligible whistleblowers against action taken in reprisal for disclosing Reportable Conduct. Maintaining confidentiality is a crucial component of this protection.

5. Protection and support for whistleblowers

A. Whistleblower protections

The NRL is committed to ensuring confidentiality in respect of all matters raised under this Policy, and that those who make a report are treated fairly and do not suffer detriment.

(i) Confidentiality and protecting the whistleblower’s identity

Subject to compliance with legal requirements, upon receiving a report under this Policy, the NRL will only share your identity as a whistleblower or information likely to reveal your identity if:

• you consent;
• the concern is reported to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA), the Tax Commissioner or the police; or
• the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

If the NRL needs to investigate a report, it may disclose information that could lead to your identification, but it will take reasonable steps to reduce this risk. Any disclosures of your identity or information likely to reveal your identity will be made on a strictly confidential basis.

(ii) Protection against detrimental treatment

A person who makes a report under this Policy is protected from detrimental treatment. Detrimental treatment includes victimisation, harassment, threats, disciplinary action, bias or other unfavourable treatment arising out of or connected to you making a report under this Policy.

If you are subjected to detrimental treatment as a result of making a report under this Policy you should either inform a Protected Disclosure Officer or raise it in accordance with section 4 of this Policy.

While this Policy prohibits detrimental conduct against a person who has made a disclosure of Reportable Conduct, the Policy will not protect you if you have been involved in or connected to any Reportable Conduct the subject of the disclosure. For example, if you have been involved in a fraud involving the NRL or ARLC and subsequently disclose the fraud this Policy does not prevent the NRL or ARLC from investigating or taking action against you (as appropriate) in relation to the fraudulent activity.

(iii) Protection of files and records

All files and records created from an investigation will be retained securely. Unauthorised release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower will be a breach of this Policy.

A release of information in breach of this Policy will be regarded as a serious matter and will be dealt with under NRL’s disciplinary procedures. In the case of a serious breach, a whistleblower may be able to seek remedies through the courts if they suffer loss, damage or injury because of a disclosure and the NRL failed to take reasonable precautions and exercise due diligence to prevent the detrimental conduct.

Australian law also contains a number of statutory protections for whistleblowers who disclose information relevant to a contravention of that legislation. The Corporations Act 2001 (Cth) contains specific whistleblower protection in relation to reported disclosures regarding breach of the Corporations Law. Statutory protections for whistleblowers also exist within the tax legislation and for public officials.

B. Whistleblower support

The NRL offers the following support for whistleblowers:

• access to the NRL’s confidential 24/7 counselling service - Benestar (Australia - 1300 360 364, New Zealand - 0800 360 364);
• support as required from the People and Culture team to manage any ongoing issues the whistleblower may have; and/or
• encouraging the whistleblower to contact external support agencies (Lifeline - 13 11 14, Beyond Blue - 1300 22 4636).

6. What happens if I make a report?

The NRL will properly assess and, if appropriate, investigate in a timely manner any disclosures of Reportable Conduct it receives. The objective of the investigation is to identify any evidence that either substantiates or refutes the original disclosure.

Where a Protected Disclosure Officer considers the matter requires further investigation, they will delegate any matter to be investigated to an appropriately qualified person (Investigator) at their discretion. The Investigator responsible for managing any matter will be required to follow strict procedures. These procedures generally involve:

• undertaking a fair, independent and discreet investigation into the alleged disclosable matter to determine whether there is evidence to support any matter raised;
• respecting individual confidentiality;
• ensuring procedural fairness and objectivity, interviewing any relevant person to understand their perspective;
• proceeding with due care and ensuring a timely investigation; and
• report all findings to a Protected Disclosure Officer who will determine an appropriate response.

The NRL will not disclose information that is likely to lead to the identification of the whistleblower as part of its investigation process without their consent unless:

• the information does not include the whistleblower’s identity;
• the information relating to the whistleblower’s identity; and
• it is reasonably necessary for investigating the issues raised in the disclosure.

While the particular investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, a Protected Disclosure Officer or investigator will contact you to discuss the investigation process including who may be contacted and such other matters as are relevant to the investigation.

The findings of an investigation will be recorded and the Protected Disclosure Officer will determine an appropriate response and (subject to confidentiality and considerations of privacy against whom allegations are made) will inform the whistleblower of the outcome.

Where a report is made anonymously the NRL will consider the material and will investigate the matter based on the information available to it.

7. Fair treatment of individuals mentioned in a disclosure

The NRL will ensure employees who are mentioned in, or are the subject of, a disclosure made under this Policy are treated fairly by:

• handling a disclosure confidentially where practicable;
• assessing a disclosure individually and determining whether further investigation is required in the circumstances;
• conducting any investigation in relation to a disclosure objectively, fairly and independently and in accordance with its policies;
• advising an employee who is the subject of a disclosure about the disclosure as and when required by principles of natural justice and procedural fairness and prior to any disciplinary actions being taken; and
• informing an employee who is the subject of a disclosure about the available support services.

8. Policy implementation and reporting

The NRL makes this Policy available to its officers and employees by the following methods:

• posting this Policy on the NRL Intranet;
• explaining the policy to staff;
• incorporating this Policy in NRL employee induction information packs and training for new starters; and
• including the policy on its website (pan66.com).

Further information regarding this Policy may also be obtained from one of the Protected Disclosure Officers listed in this Policy from time to time.

All reports made pursuant to this Policy will be reported to the Chair of the ARLC’s Audit and Risk Committee and the Chair of the ARLC.

This Policy will be reviewed regularly (and at least every two (2) years) to ensure that it remains effective, compliant with applicable legislative requirements and meets best practice.

Version 1.2 – July 2024

Approved by the Australian Rugby League Commission.